ICE Trust CDS Clearing Buy-side Client Overview DCO Model

1. ICE Trust CDS Clearing Buy-side Client Overview DCO Model January 2011 www.theice.com

2. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 2

3. ICE Introduction IntercontinentalExchange (ICE) is the leading operator of integrated futures and over-the-counter (OTC) markets, clearing, processing and data services for global derivatives markets. ICE Integrated Marketplace • ICE established in 2000, (NYSE: ICE) market capitalization of $8.7B* • Member of S&P 500 and Russell 1000 • 3 Futures and 2 OTC global derivatives markets across energy, agriculture, equity indexes, FX, and credit • Five clearing houses for futures and OTC markets in U.S., Europe & Canada • Market participants in more than 70 countries • Significant depth and investment in CDS market *As of January 3, 2011 3

4. ICE CDS Milestones and Volume Cleared ICE Global CDS Cumulative Volume ICE CDS Clearing Surpasses $14 Trillion Globally • Over $15 Trillion notional cleared globally • ICE Trust cleared over $4.6 Billion in client-related notional ICE CDS Clearing Surpasses $10 Trillion Globally ICE Trust Launches Buy-side Clearing ICE Trust/ICE Clear Launches Single Names 12/09 In Billions ICE Trust Surpasses $3 Trillion ICE Clear Launches CDS Clearing 7/09 ICE Trust Launches CDS Clearing 3/09 As of January 21, 2011 4

5. Current Status - Products and Clearing Participants As of January 14, 2011 5

6. Why Clear with ICE? • Gross margin held at ICE, not at Futures Commission Merchant/Broker Dealer* • Default protections designed to work within existing bankruptcy laws • Pre and post default portability of positions and collateral • World class risk management specifically designed for CDS • Guaranty fund covers simultaneous default of 2 largest Clearing Participants Customer Protection Expertise & Depth • Over 250 cleared CDS products across US and Europe • 14 dealers and hedge fund and asset managers actively clearing today • Managed numerous Credit Events, Succession Events and Matured Contracts • Leading market connectivity processing thousands of trades a day Ease of Doing Business • Leverage existing infrastructure • Trades cleared intra-day, on near real-time basis • Open access provided through support of multiple affirmation platforms • No costly significant technology build • * Dodd-Frank Act requires any entity that accepts customer funds in connection with cleared swaps be registered with the CFTC as a FCM for broad based indices and with the SEC as a Broker-Dealer (BD) for cleared narrow based indices and single name CDS 6

7. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 7

8. Margin Segregation Gross Margin is held at ICE, not at the Futures Commission Merchant/Broker Dealer CLIENT A CLIENT A Gross IM $2MM CLIENT B Gross IM $1MM • FCMs required to collect the Gross Initial Margin (ICE Minimum Initial Margin) from each client • Margin calculator available to clients to calculate Margin requirements – full transparency provided Gross IM $2MM • FCMs required to post total Gross Initial Margin to ICE • FCMs can charge an Excess Initial Margin. Client and FCM negotiate where Excess Margin is held • FCM and Client negotiate the timing of margin payment FCM Gross IM = 3MM ICE-FCM Client Omnibus Account • Gross IM held at ICE in the FCM’s Client Omnibus Account • Client Account is fully segregated from the House Account Gross IM = 3 MM for Client A and Client B * Customer segregation is subject to change following the promulgation of final rules by the CFTC and SEC under the Dodd-Frank Act. 8

9. Risk Management Waterfall Risk Management Waterfall* Layers of Protection Ensure CP has sufficient financial resources, operational capabilities and risk management experience Membership Criteria 1. Defaulting Buy-side Margin 2. Defaulting CP House Margin Initial Margin Requirement Daily margin call based on dynamic stress test regime 3. Defaulting CP Guaranty Fund Mark-To-Market Margin Requirement Daily MTM based on EOD settlement prices 4. Non-default clients of CP (net only) 5. ICE Priority Guaranty Fund (GF) Intra-day Risk Monitoring Special Margin Call Execution Additional margin can be called unusual market fluctuations 6. Non-defaulting CPs GF/ ICE remaining GF Additional collateral to mutualize losses under extreme market scenarios Guaranty Fund 7. Assessment of CPs *CP Default Related to Client Positions Additional Assessment Rights Oblige CPs to contribute additional default funding 9

10. Initial Margin Requirement Dynamic Stress-Based Regime Summary Of Risks Captured by Model Components Spread Response Requirement • Risk associated with spread moves, curve shape changes and recovery rates • JTD requirement based on expected losses of a default Jump-To-Default (JTD) Requirement • Costs associated with Bid/Offer exposure upon portfolio liquidation Liquidity/Basis Risk Requirement • Risk associated with parallel moves in interest rates Interest Rate Risk Requirement Concentration Requirement • Costs associated with large position liquidation Initial Margin Requirement • Total risk requirement 10

11. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 11

12. How To Clear a Trade ICE Supports the Existing OTC Model and Multiple Platforms Trade Execution & Capture Affirmation & Clearing Consent Clearing & Confirmation by ICE Affirmation Platform Voice or e-trade Trade Capture ICE FCM Affirms and Routes to ICE Trade Routed to TIW Buy-side Affirms, Allocates and Routes to FCM Trade Cleared & Confirmed ICE Runs Risk Filter Checks and Accepts Trade Executing Broker Alleges Block Trade Trades Cleared Intra-day on Near Real-Time Basis No Changes to Trade Execution Multiple Platforms Supported Multiple Affirmation Platforms Supported (ICE Link, Bloomberg, Tradeweb) 12

13. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 13

14. Key Provisions of the Dodd-Frank Act - Title VII Jurisdiction • Mandates the CFTC regulate swaps including broad based indices (e.g., index CDS) and the SEC regulate security-based swaps including narrow based indices and single name CDS Clearing Mandate Clearing will be mandated for standardized swaps as determined by the CFTC and SEC Execution • Swaps that are required to be cleared must be executed on a swap execution facility (SEF), designated contract market or national securities exchange • Requires any entity that accepts customer funds in connection with cleared swaps be registered with the CFTC as a FCM for broad based indices and with the SEC as a Broker-Dealer (BD) for cleared narrow based indices and single name CDS U.S. Customer Clearing Margin Segregation • Funds collected are “customer property” and must be held in an account segregated from non-customer (house) funds 14

15. Areas of Impact for ICE Trust • ICE Trust will transition to a DCO upon effective date of Dodd-Frank in July of 2011 • ICE Trust secured an extension of its existing SEC exemptive order through the Dodd-Frank effective date and will be deemed a Securities Clearing Agency on the effective date • Clearing Participants must clear customer business through FCM/BD entity Legal Structure • Customer relationship to FCM governed by a bilateral futures agreement • Customer relationship to BD governed by a securities account agreement • ICE Trust Rules govern CDS clearing • No separate ICE Trust Addendum for customer and FCM/BD to bilaterally execute Documentation Customer Segregation • Portability and customer segregation governed by CFTC and SEC regulations • CFTC regulated customer omnibus account (Cleared OTC Derivatives Account Class 4(d)(f)) • ICE Trust will seek to hold both indices and single names in the same OTC account class Product/ Infrastructure • CDS product will remain the same • Upfront fees will move to T+1 and netted with margin movements • Customers and CPs can leverage current OTC technology infrastructure (e.g., ICE Link) • ICE Trust is seeking regulatory approval for portfolio margining (“Index Decomposition” margin methodology) • Acceptable margin collateral and permissible margin investments to be determined once final rules are published by CFTC and SEC Margin Methodology 15

16. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 16

17. ICE Timeline Present • ICE Trust live with client clearing under Derivatives Clearing Member (DCM) Model • Margin Simulation Calculator available • ICE Trust and CPs operationally ready to support client clearing under the DCO Model • Client testing under the DCO Model Q2 2011 • Upon July 2011 effective date of the Dodd-Frank Act: • ICE Trust deemed a DCO and SCA • ICE Trust and CPs live with client clearing under the DCO Model • Rollout of IG NA single names for client clearing • Portfolio Margining (index/single names) • Start rollout of HY single names Q3 2011 17

18. Agenda • Overview of ICE CDS Clearing • Client Clearing Solution • Operational Workflow • Impact of Dodd-Frank Act on ICE Trust CDS Clearing • ICE Timeline • Client Next Steps 18

19. Client Next Steps To begin clearing CDS, Buy-side clients need to: • Establish relationships with one or more Clearing Participant(s)1 • Execute legal documentation with Clearing Participant(s) and review ICE Trust Rules • Establish access to a connectivity provider2 • The Margin Simulation Calculator is available for estimation of margin requirements: • Provides full transparency into the initial margin methodology • Provides detailed analysis of results provided at the net position level • Allows users to utilize existing positions or upload custom portfolios to run “what if” scenarios • Access available through the ICE Link web interface • 1 Clearing Participants as of January 7th, 2011 - Bank of America/Merrill Lynch, Barclays, BNP Paribas, Citi, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JPMorgan Chase, Morgan Stanley, Nomura, RBS and UBS. Societe General & Unicredit AG are Participants of ICE Clear only. • 2 Connectivity providers include ICE Link, Bloomberg, Tradeweb 19

20. How to Stay Updated ICE Website – www.theice.com Regularly updated and provides information on Clearing Eligible products and EOD prices ICE CDS Newsletter Monthly newsletter providing a summary of ICE CDS developments. To subscribe, visit the ICE Subscription Center at www.theice.com/subscribeand choose Credit Derivatives from the Products menu ICE Webinars Webinars will be made available on the website explaining the ICE clearing model in more detail 20

21. US Clearing Participant Contacts 21

22. European Clearing Participant Contacts 22

23. ICE Contacts Paul Swann President ICE Clear Europe Email: paul.swann@theice.com Office: +44 (0)20 7065 7615 Suzanne Hubble Director – CDS Development ICE Clear Europe Email: suzanne.hubble@theice.com Office: +44(0)20 7065 7625 Helen Fermor CDS Product Manager ICE Clear Europe Email: helen.fermor@theice.com Office: +44(0)20 7065 7626 Chris Edmonds President ICE Trust US Email: chris.edmonds@theice.com Office: 312-836-6810 Peter Barsoom Chief Operating Officer ICE Trust US Email: peter.barsoom@theice.com Office: 212-323-8508 Corry Bazley Director – Sales and Marketing ICE Trust US Email: corry.bazley@theice.com Office: 212-323-6022 23